Privacy Policy

Last Updated on June 01, 2020

Introduction

Catalyca Private Limited (“Catalyca”), is a company incorporated under the laws of India, providing travel related services through its website (www.trotcat.com) referred to as the “Platform”.

Catalyca provides its customers or users (hereafter referred to as “User”) travel itinerary information including ability to create new itineraries or update existing itineraries, travel schedule & status information updated from time to time and other associated information for enabling convenience during the User’s travels such as booking cabs, checking neighbourhood areas or maps, enabling online check-in, setting up meeting calendars and personal reminders in relation to the User’s travels anywhere worldwide (“Services”). These Services may be availed by the User based on the User’s bookings or arrangements made with various third party vendors such as airlines, hotels, etc (“Travel Suppliers “).

Catalyca collects and processes personal information about the User with their consent, with the only exception being any information that constitutes a pre-requisite for Catalyca to provide the Services to User and operate the business, meeting applicable legal and contractual obligations related to the Services or protecting the security of systems and customers.

Catalyca respects the User’s privacy and is committed to protecting the User’s personally identifiable information by which they can be identified (hereafter referred as “User Information”) by handling it responsibly and safeguarding it using appropriate technical and organizational measures.

This privacy policy (“Policy”) outlines the types of User Information collected on the Platform, how Catalyca collects, uses, processes and shares this information provided in relation to the provision of the Services, how Catalyca safeguards such information and how users may exercise their rights with respect to User Information.

The Policy applies only to User Information collected by Catalyca through the Platform and does not apply to services that link to other privacy policies, including any third-party websites or applications or services that the User may connect to from the Platform. Catalyca is not responsible for the privacy practices or content of such third parties, which may be materially different from this Policy. The User is encouraged to review the privacy statements and policies of such third parties.

By using or accessing the Platform, the User hereby agrees with the terms of this Privacy Policy and the contents herein.

From time to time Catalyca may update the Policy. The latest revision date of the Policy shall be reflected at the beginning of the Policy content as depicted in this Platform. If the User does not agree with the changes, the User should discontinue the use of the Platform immediately.

This Policy is written in the English language. If any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall prevail.

For any queries, User may contact the Data Privacy Representative of Catalyca at:
Email: UserEnquiry@Catalyca.com

Types of User Information:

Catalyca may collect the following personal and sensitive information about the User from the User or their employer or other authorized representative, while transacting through the Platform:

Name (including short name and legal name), gender, age and date of birth
Contact information, such as address, email, and mobile phone number
Loyalty program membership number and/or travel supplier preferences
IP address, internet type such as Wi-Fi or mobile data
Device information (device id, model, platform, version, manufacturer and serial number)
Browser information, logs, language, clickstream information, access times
Details of how the User uses the Platform and/or Services
Travel related preferences (such as aircraft aisle seating or hotel king bed or meal preferences or health aspects during travels)
Travel history based on past trips of the User whose itinerary is available in the Platform
User’s travel related documents such as tickets, vouchers, expense receipts or other materials

If the User provides personal information to Catalyca regarding other persons, the User expressly agrees:

To inform such persons about the contents of this Policy
To obtain any legally-required consent, for the collection, use, disclosure, and transfer (including cross-border transfer) of such persons’ personal information, from such persons in accordance with the legal and regulatory requirements.

The Services are not intended for a User below the legal age limit for entering into binding contracts, unless permitted under applicable local laws. Catalyca does not knowingly collect any personal information from the User or the market to or solicit information from anyone under such legal age limit. If Catalyca becomes aware that a person submitting personal information is under such legal age limit, Catalyca will delete such accounts or user profiles and any related information as soon as possible. If the User believes that Catalyca might have any information from or about the User who is below such legal age limits, the User needs to immediately contact Catalyca at UserEnquiry@Catalyca.com.

User Information Collection:

From the User: Catalyca obtains User Information directly from a User, including but not limited to sources such as User profile registration forms, User updation of the profile in the Platform, purchases of Services by User on the Platform including Subscriptions, communications with Catalyca, browsing through online Catalyca websites or other materials and so on.

From other sources: Catalyca may also obtain User Information from other sources, including but not limited to, from Travel Suppliers, any authorized representatives or User’s employer. Catalyca may attach such personal information acquired to the respective User to better understand and serve the User as well as to satisfy any legal obligations.

If the User’s employer subscribes to the travel management service from Catalyca, the User may get a profile created on the Platform through their employer or may link or connect their pre-existing account with such a profile. Once such an account is established, any itineraries or travel information created for the employer’s purposes may be updated within the Platform. Catalyca will not share any of the User’s personal itineraries and related information in the Platform with their employer. If the User chooses to disconnect their Platform account from their employer’s account or if their relationship with their employer is no longer applicable, the User may reinstate the Platform account using their personal credentials instead of the business credentials that may have existed earlier. As long as the Platform account remains as a business account, all User Information shared with the User’s employer may not be removable or severable at the User’s instance alone, and the User may need to contact their employer for any such removal of information.

The Platform is hosted from globally renowned public cloud providers who may operate across multiple regions globally, including within India. Using the Platform may result in the transfer, use, processing, or storage of User Information in India or any other country where the public cloud provider operates from. Some of these jurisdictions may not have data privacy laws that provide protections equivalent to those provided in your home country.

By providing your information to us through your use of the Platform, you agree to such transfer, storage, and processing of your User Information in India or other regions.

Usage of User Information:

Catalyca may rely on the following reasons when collecting and processing User Information:

In order to perform contractual obligations, operate the business and provide Services to Customers
In the event that User has freely given, specific, informed and unambiguous consent at the time when the User Information was provided to Catalyca
In order to further legitimate interests based on Catalyca’s evaluation that such processing is fair, reasonable and balanced
In order to further legitimate interests of the User or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the User which require protection of personal data, in particular where the data subject is a child.

Catalyca does not sell or trade upon any of the User Information without the User’s consent. The foregoing information collected about the User is put to the following (including but not limited to) uses:

To create and maintain User’s profile
To create and maintain User’s travel itineraries
To enable User manage or store all communications, documentations and reference information related to their purchases/bookings
To send the User, push message alerts regarding flight delays, terminal or gate changes, and other notifications specific to the User’s active itineraries through the Platform. These messages may also get delivered via SMS, WhatsApp or similar media specific to the User
To inform the User about any actions they need to take in relation to the Services
To update User on new features and capabilities of the Platform
To send offers or promotions of Catalyca or its partners
To meet legal and regulatory requirements, including to enforce the Catalyca Terms of Use and or protecting Catalyca’s business, partners, or users including against any fraudulent, unauthorized, infringing, or illegal activity.

Catalyca may share non-personal, anonymized and aggregated information with third parties for various purposes, including data analytics, research, submissions, thought leadership and promotional activity.

In order to have a better experience and to use all features in the android version of the Platform, Catalyca may need the following permissions from the User:

Camera: Catalyca will not access the User’s photos or camera without first getting User’s permission. Catalyca will also not scan or import User’s photo library or camera roll. If User grants permission to Catalyca to access their photos or camera, Catalyca would only collect images that User specifically chooses to share.
Location: Catalyca will not gather or use the specific location of User’s mobile device (by using, for example, GPS or Bluetooth, not including IP address) without first getting User’s explicit permission. If User grants permission to Catalyca to access their location, Catalyca would be able to offer the User, location specific events, reminders and deals, finding directions to specified locations, and provide a more personalized or contextualized experience.
Third Party: If User grants permission, Catalyca may invoke third-party services for displaying content from external platforms, SPAM protection, hosting and backend infrastructure, infrastructure monitoring, content commenting, interaction with external social networks and platforms, location-based interactions, social features, contacting the User, User database management, targeted advertising and remarketing and behavioral targeting.

Avenues where User Information is shared:

In connection with any of the purposes outlined in aforesaid sections, Catalyca may disclose details about the User, subject to their consent, to:

Third party partners or vendors of Catalyca who are directly involved in provision of Services purchased by User or to enable Catalyca analyse the usage of Services to User
Third parties to the extent that User has enabled a connection between their Platform account and a third-party service.
Employer of the User, as applicable
Competent authorities (including courts and authorities regulating Catalyca for compliance, audits or any investigations and in connection with discharging obligations of the User Agreement)
Other organizations to whom Catalyca may transfer its business, assets, rights and/or obligations

Catalyca does not authorize third party providers who get access to such information, to use such information other than to provide the services to Catalyca. Catalyca uses reasonable efforts to ensure that such providers protect the privacy of such information in adherence to this privacy policy, however, Catalyca shall not be liable to the User for any non-adherence by such providers. Users are requested to review the privacy policies of such providers from time to time.

If User would like to receive more information about this practice and to know their choices about not having this information used by a third party, please email to UserEnquiry@Catalyca.com.

Catalyca may also transfer the User Information to countries:

which are linked to User’s engagement with Catalyca
from which User regularly receives or transmits information
where partners or vendors of Catalyca conduct their activities.

For Users who are resident in countries other than India, when Catalyca, or their permitted third parties transfer User Information outside of their country of residence, Catalyca will use best endeavour to impose contractual obligations on the recipients of such data to protect User’s User Information to the standards required in such country of residence. Catalyca will also use best endeavour to require the recipient to subscribe to international frameworks intended to enable secure data sharing. If Catalyca transfers User Information outside such country of residence in other circumstances (for example, as required by law), Catalyca will make sure it remains adequately protected.

The privacy regulations of such countries or jurisdictions where such information is transmitted, may be different to those of the country where the User resides. User consents to such transmission of information for the purposes as set out in this privacy policy.

User may contact Catalyca to obtain details of the specific entities or countries where such information may be shared in a given transaction.

User Information Protection:

Catalyca has implemented appropriate technical and organizational measures to safeguard and help prevent unauthorized access to User Information and to maintain data security. These safeguards take into account the sensitivity of the information that is collected, processed and stored, and the current state of technology. Catalyca follows generally accepted industry standards to protect the personal information submitted by User.

Catalyca maintains data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of the User Information. However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, while Catalyca makes best endeavour to use commercially acceptable means to protect the User Information, Catalyca does not guarantee its absolute security.

Catalyca assumes no liability or responsibility for disclosure of User’s information due to errors in transmission, unauthorized third-party access, or other causes beyond their control. User plays an important role in keeping their personal information secure. User should not share their user name, password, or other sensitive information for their Platform account with anyone. If Catalyca receives instructions using the User’s user name and password, Catalyca will consider that the User has authorized such instructions and disclaims all liability in relation to the same.

User’s Data Protection Rights:

User’s data protection rights are given below:

Right to access – User can ask to verify whether Catalyca is processing personal data about them, and if so, to provide more specific information.
Right to correction – User can ask to correct Catalyca’s records if they believe that such records contain incorrect or incomplete information about them.
Right to erasure – User can ask to erase, delete or remove their personal data after they withdraw their consent to processing or when Catalyca no longer needs it for the purpose it was originally collected, except that Catalyca may not be able to remove records of any past transactions by the User on the Platform or if Catalyca needs to retain any of the User Information to comply with legal or regulatory requirements or obligations.
Right to processing restrictions – User can ask to temporarily restrict Catalyca’s processing of their personal data if they contest the accuracy of their personal data, prefer to restrict its use rather than having to erase it, or need Catalyca to preserve it for them to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether Catalyca has overriding legitimate grounds to process it. User can ask Catalyca to inform them before such a temporary restriction is lifted.
Right to portability – In some circumstances, where User has provided personal data to Catalyca, they can ask Catalyca to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another specified party, if it is technically feasible.
Right to automated individual decision-making – User can ask Catalyca to review any decisions made about them which was made solely based on automated processing, including profiling, that produced legal effects concerning the User or similarly significantly affected the User.
Right to object to direct marketing including profiling – User can object to Catalyca’s use of their personal data for direct marketing purposes, including profiling. User can also unsubscribe from select services and communications by opting-out using the links provided in such communications. Catalyca may need to keep some minimal information to comply with User’s request to cease marketing to them.
Right to withdraw consent – User can withdraw their consent that was previously given to one or more specified purposes to process their personal data. This will not affect the lawfulness of any processing carried out before such withdrawal. However, this may lead to Catalyca not being able to provide certain products or services to User.

Catalyca may need to request specific information from User to help confirm their identity and ensure their right to access the information or to exercise any of their other rights. This helps Catalyca to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless their request is clearly unfounded or excessive. Depending on the circumstances, Catalyca may be unable to comply with their request based on other lawful grounds, in which case, Catalyca will ensure that User is notified about the same without undue delay.

Even if User does not grant permission to collection or use of majority of the User Information, Catalyca may still need to contact the User with important transactional information related to their account and use of Platform, such as matters relating to user credentials, security, billing, etc.

User may check and amend their User Profile information available and stored with Catalyca under the menu “Profile” within the Platform. To delete a user profile, User may send an email to UserEnquiry@Catalyca.com.

If User has any questions, comments, or complaints or wishes to access a copy of their personal data or to correct it in case of any inaccuracies, the User may send an email to UserEnquiry@Catalyca.com. Catalyca may reserve the right to charge User a fee, as permitted by applicable law, and may decline requests that are unreasonable, prohibited by law, or are not required to be honoured by applicable law.

User Information Retention:

Catalyca will retain User Information for the longer of:

the period necessary for the relevant User transactions or Services
the period for which the User remains as an active user on the Platform
any retention period that is required by law, for maintenance of appropriate business and financial records, or for other reasons
the period in which litigation or investigations might arise in respect of the Services

Since the aforesaid needs may vary for different types of User Information in the context of different types of Services, actual retention periods may vary significantly.

Even after a User account is terminated, Catalyca may retain User data for as long as it has a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce Catalyca’s contractual agreements. Catalyca may retain and disclose such data pursuant to this Policy after the User account has been terminated.